The case for leapfrogging ICD-10 and holding out for ICD-11 just got a lot more curious. And though it’s not here yet, when ICD-11 is ready, it will be something ICD-10 cannot be: A 21st Century classification system.
Now that HHS Secretary Kathleen Sebelius has thrown her department’s hat in the ring, saying late Wednesday that HHS intends to delay ICD-10, the most pertinent question is how long will HHS push back compliance?
“My opinion is that CMS won't be able to announce three months or six months of delay for ICD-10,” says Mike Arrigo, CEO of consultancy No World Borders (pictured above). “They will need to announce a delay from Oct. 1, 2013 to at least Oct. 1, 2014 because of CMS fiscal planning calendars.”
Others in the industry are suggesting that even one year is not enough to lighten the burden on physicians, providers and payers to make the transition smoother.
“I have a gut feeling they’ll go for two years, who knows?” speculates Steve Sisko, an analyst and technology consultant focused on payers and ICD-10. “Maybe January 2015?”
No more mixed signals
There it is on the Department of Health and Human Services Web site, a crystal-clear headline atop a brief explanatory statement: HHS announces intent to delay ICD-10 compliance deadline.
“We have heard from many in the provider community who have concerns about the administrative burdens they face in the years ahead,” Sebelius said in the statement. “We are committing to work through the rulemaking process, with the provider community, to reexamine the pace at which HHS and the nation implement these important improvements to our healthcare system.”
Whereas acting CMS administrator Marilynn Tavenner was perhaps politically vague when speaking at an AMA meeting on Tuesday by saying that CMS would reexamine the timing of ICD-10 compliance, Sebelius’ statement was careful to erase any doubt about HHS’s plans.
“HHS will announce a new compliance date in forthcoming rulemaking,” the statement explains.
Neither Tavenner nor Sebelius clearly outlined “the rulemaking process” to which each referred. But any kind of rulemaking by the federal government tends to take a while, and there’s no reason to suggest that this instance will differ.
A formal process could take as long as a year, while the informal, conducted through the Federal Register, typically calls for a 180-day response period, after which the comments are taken into consideration to shape a new proposed rule. That, in turn, must be evaluated, eating up more clicks of the clock.
“The fact that [Tavenner] mentioned going through a rulemaking process implies to us that this will take a long time,” Wendy Whittington, MD, CMO of Anthelio Healthcare Solutions, said. “A short delay would be much more tolerable than a long one.”
If HHS has a tack for fast-tracking the rulemaking process for ICD-10, thus far it has not explained that. But if the agency intends only to change the compliance deadline then perhaps there is a way to abridge that cycle.
A time to question the value of ICD-10
Prior to the HHS statement, the AMA praised and AHIMA panned Tavenner's commitment to reexamine the timing.
In an increasingly heated industry-association Civil War, both groups have fired shots, with the AMA calling on Sebelius and House Speaker John Boehner to block ICD-10 entirely, and AHIMA urging the industry to continue apace toward the new code sets.
Any delay, according to Dan Rode, AHIMA vice president of advocacy and policy, would increase costs while diminishing the value of ICD-10 and other health IT projects, including, of course, meaningful use.
HHS acknowledged the need for ICD-10. “ICD-10 codes are important to many positive improvements in our healthcare system,” says Sebelius.